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The firm OpenVault, a provider of software that measures data consumption for ISPs reported that the average monthly data use by households grew from 201.6 gigabytes in 2017 to 268.7 gigabytes in 2018 – a growth rate of 33%. The company also reported that the medium use per household grew from 103.6 gigabytes in 2017 to 145.2 gigabytes in 2018 – a growth rate of 40%. The medium represents the midpoint of users, with half of all households above and half below the medium.

To some degree, these statistics are not news because we’ve known for a long time that broadband usage at homes, both in total download and in desired speeds has been doubling every three years since the early 1980s. The growth in 2018 is actually a little faster than that historical average and if the 2018 growth rate was sustained, in three years usage would grow by 235%. What I find most impressive about these new statistics is the magnitude of the annual change – the average home used 67 more gigabytes of data per month in 2018 than the year before – a number that would have seemed unbelievable only a decade ago when the average household used a total of only 25 gigabytes per month.

There are still many in the industry who are surprised by these numbers. I’ve heard people claim that now that homes are watching all the video they want that the rate of growth is bound to slow down – but if anything, the rate of growth seems to be accelerating. We also know that cellular data consumption is also now doubling every two years.

This kind of growth has huge implications for the industry. From a network perspective, this kind of bandwidth usage puts a big strain on networks. Typically the most strained part of a network is the backbones that connect to neighborhood nodes. That’s the primary stress point in many networks, including FTTH networks, and when there isn’t enough bandwidth to a neighborhood then everybody’s bandwidth suffers. Somebody that designed a network ten years ago would never have believed the numbers that OpenVault is reporting and would likely not have designed a network that would still be sufficient today.

One consequence of the bandwidth growth is that it’s got to be driving homes to change to faster service providers when they have the option. A household that might have been happy with a 5 Mbps or 10 Mbps connection a few years ago is likely no longer happy with it. This has to be one of the reasons we are seeing millions of homes each year upgrade from DSL to cable modem each year in metropolitan areas. The kind of usage growth we are seeing today has to be accelerating the death of DSL.

This growth also should be affecting policy. The FCC set the definition of broadband at 25/3 Mbps in January of 2015. If that was a good definition in 2015 then the definition of broadband should have been increased to 63 Mbps in 2019. At the time the FCC set that threshold I thought they were a little generous. In 2014, as the FCC was having this debate, the average home downloaded around 100 gigabytes per month. In 2014 the right definition of broadband was probably more realistically 15 – 20 Mbps and the FCC was obviously a little forward-looking in setting the definition. Even so, the definition of broadband should be increased – if the right definition of broadband in 2014 was 20 Mbps, then today the definition of broadband ought to have been increased to 50 Mbps today.

The current FCC is ignoring these statistics for policy purposes – if they raise the definition of broadband then huge numbers of homes will be classified as not having broadband. The FCC does not want to do that since they are required by Congressional edict to make sure that all homes have broadband. When the FCC set a realistic definition of broadband in 2015 they created a dilemma for themselves. That 2015 definition is already obsolete and if they don’t change it, in a few years it is going to be absurdly ridiculous. One only has to look forward three years from now, when the definition of broadband ought to be 100 Mbps.

These statistics also remind us of the stupidity of handing out federal subsidies to build technologies that deliver less than 100 Mbps. We still have two more years of CAF II construction to upgrade speeds to an anemic 10 Mbps. We are still handing out new subsidies to build networks that can deliver 25/3 Mbps – networks that are obsolete before they are completed.

Network designers will tell you that they try to design networks to satisfy demands at least seven years into the future (which is the average life of many kinds of fiber electronics). If broadband usage keeps doubling every three years, then looking forward seven years to 2026, the average home is going to download 1.7 terabytes per month and will expect download speeds of 318 Mbps. I wonder how many network planners are using that target?

The final implications of this growth are for data caps. Two years ago when Comcast set a terabyte monthly data cap they said that it affected only a few homes – and I’m sure they were right at the time. However, the OpenVault statistics show that 4.12% of homes used a terabyte per month in 2018, almost double from 2.11% in 2017. We’ve now reached that point when the terabyte data cap is going to have teeth, and over the next few years a lot of homes are going to pass that threshold and have to pay a lot more for their broadband. While much of the industry has a hard time believing the growth statistics, I think Comcast knew exactly what they were doing when they established the terabyte cap that seemed so high just a few years ago.

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Windstream CEO Tony Thomas recently told investors that the company plans to stress wireless technology over copper going into the future. The company has been using point-to-point wireless to serve large businesses for several years. The company has more recently been using fixed point-to-multipoint wireless technology to satisfy some of it’s CAF II build-out requirements.

Thomas says that the fixed wireless technology blows away what could be provided over the old copper plant with DSL. In places with flat and open terrain like Iowa and Nebraska the company is seeing rural residential broadband speeds as fast as 100 Mbps with wireless – far faster than can be obtained with DSL.

Thomas also said that the company is also interested in fixed 5G deployments, similar to what Verizon is now starting to deploy – putting 5G transmitters on poles to serve nearby homes. He says the company is interested in the technology in places where they are ‘fiber rich’. While Windstream serves a lot of extremely rural locations, there also serve a significant number of towns and small cities in their incumbent service areas that might be good candidates for 5G.

The emphasis on wireless deployments puts Windstream on the same trajectory as AT&T. AT&T has made it clear numerous times to the FCC that they company would like to tear down rural copper wherever it can to serve customers with wireless. AT&T’s approach differs in that AT&T will be using its licensed cellular spectrum and 4G LTE in rural markets while Windstream would use unlicensed spectrum like various WISPs.

This leads me to wonder if Windstream will join the list of big telcos that will largely ignore its existing copper plant moving into the future. Verizon has done it’s best to sell rural copper to Frontier and seems to be largely ignoring its remaining copper plant – it’s the only big telcos that didn’t even bother to chase the CAF II money that could have been used to upgrade rural copper.

The new CenturyLink CEO made it clear that the company has no desire to make any additional investments that will earn ‘infrastructure returns’, meaning investing in last mile networks, both copper and fiber. You can’t say that Frontier doesn’t want to continue to support copper, but the company is clearly cash-stressed and is widely reported to be ignoring needed upgrades and repairs to rural copper networks.

The transition from copper to wireless is always scary for a rural area. It’s great that Windstream can now deliver speeds up to 100 Mbps to some customers. However, the reality of wireless networks are that there are always some customers who are out of reach of the transmitters. These customers may have physical impediments such as being in a valley or behind a hill and out of line-of-sight from towers. Or customers might just live to far away from a tower since all of the wireless technologies only work for some fixed distance from a tower, depending upon the specific spectrum being used.

It makes no sense for a rural telco to operate two networks, and one has to wonder what happens to the customers that can’t get the wireless service when the day comes when the copper network gets torn down. This has certainly been one of the concerns at the FCC when considering AT&T’s requests to tear down copper. The current FCC has relaxed the hurdles needed to tear down copper and so this situation is bound to arise. In the past the telcos had carrier of last-resort obligations for anybody living in the service area. Will they be required to somehow get wireless signal to those customers that fall between the cracks? I doubt that anybody will force them to do so. It’s not far-fetched to imagine customers living within a regulated telcos service area who can’t get telephone or broadband service from the telco.

Customers in these areas also have to be concerned with the future. We have wide experience that the current wireless technologies don’t last very long. We’ve seen electronics wear out and become functionally obsolete within seven years. Will Windstream and the other telcos chasing the wireless technology path dedicate enough capital to constantly replace electronics? We’ll have to wait for that answer – but experience says that they will cut corners to save money.

I also have to wonder what happens to the many parts of the Windstream service areas that are too hilly or too wooded for the wireless technology. As the company becomes wireless-oriented will they ignore the parts of the company stuck with copper? I just recently visited some rural counties that are heavily wooded, and which were told by local Windstream staff that the upgrades they’ve already seen on copper (which did not seem to make much difference) were the last upgrades they might ever see. If Windstream joins the other list of big telcos that will ignore rural copper, then these networks will die a natural death from neglect. The copper networks of all of the big telcos are already old and it won’t take much neglect to push these networks into the final death spiral.

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The FCC has finally come to grips with the fact that big ISPs are supplying bad data to the various FCC mapping efforts that are then used to distribute FCC funding and to set national policies. The latest mapping snafu come from one-time data collection from the cellular carriers last year showing rural cellular coverage. These maps were to be used to establish a new federal fund called the Mobility Fund II which will distribute $4.53 billion for the expansion of 4G cellular coverage to rural parts of the country that have little or no cellular coverage.

The big cellular companies have been lying about their cellular coverage for years. If you look at the nationwide 4G LTE coverage maps from AT&T and Verizon you’d think that they have cellular coverage virtually everywhere except in areas like deserts and mountains. But anybody living or traveling in rural America knows better. It’s not hard to drive very far off main highways and hit areas that never see a bar of cellular coverage. And even where there is coverage, it’s still often 3G or even older technology.

When the FCC collected data for the Mobility II funding the big carriers stuck to this same flawed mapping data. It turns out that overclaiming rural cellular coverage will keep funding from going to the smaller cellular companies that still serve in many parts of rural America. Luckily the FCC effort included a challenge process and the FCC was flooded with challenges showing that cellular coverage is far worse than is claimed by the big carrier maps. There were so many challenges that the FCC put the Mobility II award process on hold until they can sort it out.

This is just one of the mapping efforts from the FCC that have been used to award billions of dollars of funding over the last decade. The FCC relied on mapping data from the big telcos to establish the areas that were eligible for the billions of dollars of CAF II funding.

Since rural areas served by the biggest telcos have been neglected for years, and since the big telcos deployed very little rural DSL outside of towns it’s not hard to identify huge swaths of rural areas that have little or no broadband. But the big telco broadband coverage data contains a ton of inaccuracies. For example, there are numerous smaller rural towns that are listed in the telco databases as having decent broadband, when the reality on the ground is broadband speeds of a few Mbps at best. It looks like the big telcos often reported marketing speeds rather than actual speeds. This inaccuracy has stopped others from seeking federal grants and loans to upgrade such towns.

I fear that rural broadband mapping is on the verge of the next crisis. As a blogger I am contacted a lot by folks in rural America describing their broadband situation. I’ve heard enough stories to convince me that the big telcos have made only a half-hearted effort at implementing CAF II. I think many homes that should have seen CAF II broadband upgrades will see zero upgrades while many others will get upgraded to speeds that don’t meet even the measly CAF II goal of 10/1 Mbps.

The big telcos are not likely to come clean about having pocketed CAF II funding rather than spending every penny to make upgrades, and so they are going to claim that the CAF II areas have been upgraded, regardless of the actual situation on the ground. Rural households that didn’t see the promised upgrades will then be counted by the FCC as having better broadband. That will make these areas off limits to future federal funding to fix what the telcos botched. We already see the newest federal grant programs having a new requirement that no more than 10% of the homes covered by federal funding can have broadband today. Because of the falsified mapping, many homes without broadband are going to be deemed to be covered and it will be a massive challenge for somebody else to get funding to help such areas. These communities will be harmed twice – once by the telcos that aren’t upgrading speeds and second by the inaccurate mapping that will stop others from funding assistance to fix the problem.

The big telcos and carriers have huge incentives to lie about rural broadband coverage. None of the big telcos or cellular carriers want to spend any of their own money in rural areas, but they love the revenues they are receiving by a captive rural customer base who pays high prices for poor broadband. The big companies are fighting hard to preserve these revenues, which means they don’t want anybody else to get funding to improve broadband. To make matters worse, the big telcos continue to eliminate technicians and maintenance budgets in rural America, making it nearly impossible for customers to get repairs and service.

I unfortunately don’t have any easy solution for the problem of crappy mapping. Perhaps the FCC could entertain challenges to the broadband maps in the same way they are accepting challenges in the Mobility II process. I know a number of rural communities that would make the effort to create accurate broadband maps if this might bring them better broadband.

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It’s that time of year when I look forward at what the next year might bring to the industry. I see the following as the biggest telecom trends for 2019:

5G Will Not Save the World (or the Industry). This will be the year when we will finally stop seeing headlines about how 5G will transform society. There will be almost no actual introduction of 5G in networks, but we’ll still see numerous press releases by the big ISPs crowing about fictional 5G achievements.

CAF II Buildout Nearly Complete, but Few Notice. The CAF II upgrades will not have the impact hoped for by the FCC. Many areas that should have gotten speed increases to at least 10/1 Mbps will get something less, but nobody will officially monitor or note it. Households that buy the upgrades to 10/1 will still feel massively underserved since those speeds are already seriously obsolete.

People Will Wonder Why They Bought 5G Cellphones and 802.11ax Routers. The wireless carriers will begin charging premium prices for 5G-capable cellular phone yet there will be no 5G cell sites deployed. Households will upgrade to 802.11ax WiFi routers without realizing that there are no compatible devices in the home. Both sets of customers will feel cheated since there will be zero improvement in performance. Yet we’ll still see a few articles raving about the performance of each technology.

FCC Will Continue to Work Themselves out of the Regulatory Business. The current FCC will continue on the path to deregulate the large carriers to the fullest extent possible. They will continue to slant every decision in the direction of the big ISPs while claiming that every decision helps rural broadband.

Rural America Will Realize that Nobody is Coming to Help. I predict that hundreds of rural communities will finally realize that nobody is bringing them broadband. I expect many more communities to begin offering money for public/private partnerships as they try desperately to not fall on the wrong side of the broadband divide.

Broadband Prices Start to Climb. 2019 will be the first year that the world will notice the big ISP strategy to significantly increase broadband prices. We saw the first indication in November when Charter increased bundled broadband prices by $5 per month – the biggest broadband price increase in my memory. All the big ISPs are hoping to have broadband prices to $90 within 5 – 7 years.

Corporate Lobbyists Will Drive Policy. In 2018 there were numerous FCC decisions that came straight from the pens of telecom lobbyists. In 2019 those lobbyists will drive state and federal telecom legislation and FCC decisions.

Comcast and Charter Continue to Eat into Cellular Market. These two cable companies will quietly, yet significantly begin eating into the cellular markets in urban areas. I still don’t expect a major reaction by the cellar companies, but by 2020 we should start seeing cellular prices take another tumble.

Household Bandwidth Usage Will Continue to Grow. There will be no slowdown in the growth of household broadband as homes add many more bandwidth-capable devices to their homes. Another few million customers will cut the cable TV cord and ratchet up bandwidth usage. Online programming will routinely first offer 4K video and we’ll see the first commercial 8K video online.

We’ll See First Significant Launches of LEO Satellites. There will be little public notice since the early market entries will not be selling rural broadband but will be supporting corporate WANs, cellular transport and the development of outer space networks between satellites.

25 New Online Programmers Emerge. There will be a flood of new online programming options as numerous companies jump into the market. We won’t see many, and possibly no failures this year, but within a few years the market reality will drive out companies that can’t gain enough market share.

Transport Price Pressure Tightens. Anybody selling transport to cellular companies will see big pressure to lower prices. Those who ignore the pressure will find out that the carriers are willing to build fiber to bypass high costs.

Big Companies Will Get Most New Spectrum. The biggest ISPs and cellular carriers will still gobble up the majority of new spectrum, meaning improved spectrum utilization for urban markets while rural America will see nearly zero benefits.

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I’ve been thinking about the effectiveness of federal broadband grant programs. We’ve had three recent major sets of federal grant awards – the stimulus grants of 2007, the first CAF II grants in 2015 and the recently awarded CAF II reverse auctions. We also have an upcoming e-Connectivity grant program for $600 million. I think there are lessons to be learned from studying the difference in the results between these grants. These lessons apply to State grant programs as well as any new federal programs.

Don’t Reward Slow Broadband Speeds. Probably the most bone-headed decision made by the FCC in my memory was handing out billions in CAF II to upgrade rural copper to 10/1 Mbps. This wasn’t considered decent broadband at the time of this decision and yet these upgrades continue to be funded today. The FCC could still take back the remaining CAF II money and redirect these funds to a reverse auction, which we just saw produced much faster speeds in areas with far less density than the CAF II footprint.

Keep Politics Out of It. The CAF II decision to give all of the funding to the big telcos was purely political and resulted in a huge waste of money that could have created many real broadband solutions. The FCC is supposed to be an independent agency, and it’s shameful that lobbyists were able to kill the reverse auction originally planned for CAF II. We are seeing politics back on the table with the e-Connectivity grants where Congress created a feel-good grant program, but then saddled it with a restriction that no more than 10% of homes in a study area can have existing 10/1 Mbps speeds. The reason for this provision was not even hidden, with the big telcos saying they didn’t want federal grant money to be used to compete against them.

Don’t Fund Inadequate Technologies. AT&T is using LTE cellular broadband to satisfy CAF II. This technology will never provide adequate broadband. In the recent reverse auction we saw money going to high-altitude satellite companies. Regardless of speeds that can be delivered with these satellites, the latency is so poor that it limits the ability to use the broadband for important activities like working at home or taking on-line classes.

Don’t Stress Anchor Institutions over People. The stimulus grants required middle mile providers to pop off of highways to build expensive last mile fiber to a handful of anchor institutions – schools, libraries, etc. While these anchor institutions need good broadband, so do the neighborhoods around them. This requirement added a lot of cost to the middle-mile projects as well as made it harder for anybody else to build a last mile network since the biggest bandwidth users in a community already have fiber.

Build to Industry Practices. The stimulus grants required that fiber builders conduct expensive environmental studies and historic preservation studies. That was the first time I ever saw those requirements in my forty years in the industry. Since telecom infrastructure is built almost entirely in existing public right-of-way these restrictions added a lot of cost but zero value to the projects.

Penalize Companies that Cheat. There needs to be repercussions for companies that cheat on grant applications to win the funding. The biggest area of cheating is claiming speeds that the technology can’t deliver. The FCC follows up grants with a decent speed-test program, but the worst repercussion in failing these tests is to not get funding going forward. A carrier that badly fails the speed tests should have to return the original grant funding. I’m also hearing rumors that the many rural households covered by CAF II will not get the promised upgrades – and if so, the big telcos should be forced to return a proportionate amount of that funding for homes that don’t get the promised upgrades.

As a nation we are approaching an 85% overall penetration of residential broadband. The following statistics come from the latest report from the Leichtman Group and compares broadband customers at the end of the recent 3Q of 2018 to the end of 2017.

3Q 2018

4Q 2017

Change

Comcast

26,872,000

25,869,000

1,003,000

3.9%

Charter

24,930,000

23,903,000

1,027,000

4.3%

AT&T

15,746,000

15,719,000

27,000

0.2%

Verizon

6,958,000

6,959,000

(1,000)

0.0%

CenturyLink

5,435,000

5,662,000

(227,000)

-4.0%

Cox

5,040,000

4,880,000

160,000

3.3%

Altice

4,096,300

4,046,200

50,100

1.2%

Frontier

3,802,000

3,938,000

(136,000)

-3.5%

Mediacom

1,260,000

1,209,000

51,000

4.2%

Windstream

1,015,000

1,006,600

8,400

0.8%

Consolidated

781,912

783,682

(1,770)

-0.2%

WOW!

755,100

730,000

25,100

3.4%

Cable ONE

660,799

524,935

135,864

25.9%

Cincinnati Bell

310,700

308,700

2,000

0.6%

97,662,811

95,056,435

2,123,694

2.2%

The large ISPs in the table control over 95% of the broadband market in the country. Not included in these numbers are the broadband customers served by the smaller ISPs – the telcos, WISPs, fiber overbuilders and municipalities. Cable companies continue to dominate the broadband market and now have 63.6 million customers compared to 34.0 million customers for the big telcos.

The 2.2% overall growth during the year is impressive since many have assumed that we are nearing the top of the market for broadband penetration. It’s worth noting that the US has had a housing construction boom and has added 1.6 million new housing units so far in 2018. If you assume those new homes share the same overall 85% market penetration as the rest of the country, the new homes would account for 1.36 million of the broadband gain. That means the rest of the market saw nearly a 1% overall increase in broadband penetration – a definite slowdown over prior years.

Much of the growth at the big cable companies continues to come at the expense of telco DSL. Overall, the big telcos lost a net of 328,370 customers for the year. This is mostly due to CenturyLink and Frontier, who are clearly bleeding DSL customers. The customer losses for these two companies is a bit surprising since by now each company should have activated big numbers of faster rural DSL customers, funded by the CAF II program. Companies are not required to report their performance for CAF II separately, and I have to wonder if many rural households are actually buying the improved rural broadband.

One thing that is clear about these numbers if that every company on the list ought to be considered now as an ISP, rather than as a telco or cable company. For this same 9-month period these same companies lost nearly 2.7 million cable customers while adding 2.1 million broadband customers. It’s clear that broadband is now the biggest and most important product for each of these companies.

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I recently saw the results of several rural surveys that probably tell the best story about the state of rural broadband. The two areas being studied are far apart geographically, but they are similar in many ways. The areas are both rural and are not near to a metropolitan area. The areas have some modest manufacturing and some modest amount of tourism, but neither in a big way. Both areas included some small towns, and a few of these towns have cable TV. And in both places, the customers in the rural area have poor broadband choices. These are not small isolated pockets of people, and the two surveys cover nearly 20,000 homes.

If you listen to FCC rhetoric it’s easy to think that rural broadband is improving – but in areas like these you can’t see it. These areas have both were supposed to get some upgrades from CAF II – but from what the locals tell me there have been zero improvements so far. The CAF program still has a few years to go, so perhaps there will be some modest improvement in rural DSL.

For now, the broadband situation in these areas is miserable. There are homes with DSL with speeds of a few Mbps at best, with some of the worst speeds hovering at dial-up speeds. One respondent to a survey reported that it took 8 hours to download a copy of Microsoft Office online.

The other broadband choices are also meager. Some people use satellite broadband but complain about the latency and about the small data caps. These areas both have a smattering of fixed wireless broadband – but this is not the modern fixed wireless you see today in the open plains states that delivers 25 Mbps or faster broadband. Both of the areas in the surveys are heavily wooded with hilly terrain, and fixed wireless customers report seeing speeds of 1-2 Mbps. There are a number of homes using their cell phones in lieu of home broadband – an expensive alternative if there are school kids or if any video is watched. There were customers who reported using public hotspots in nearby small towns. And there were a number of households, included many with school kids who have given up and who have no broadband – because nothing they’ve tried has worked.

As would be expected in rural areas, slow speeds are not the only problem. Even homes that report data speeds that should support streaming video complain that streaming doesn’t work. This indicates networks with problems and it’s likely the networks have high latency, are full of jitter, or are over-subscribed and have a lot of packet loss. People don’t really judge the quality of their broadband connection by the speed they get on a speed test, but instead by the ability to do normally expected activities on the Internet.

Many of these homes can’t do things that the rest of us take for granted. Many report the inability to stream video – even a single stream. This is perhaps the biggest fallacy in the way the FCC measures broadband, because they expect that a house getting a speed like 5 Mbps ought to be able to do most needed tasks. In real life the quality of many rural connections are so poor that they won’t stream video. Many people in these areas also complained that their Internet often froze and they had to constantly reboot – something that can kill large downloads or kill online sessions for school or work.

One of the biggest complaints in these areas was that their network only supported one device at a time, meaning that members of the family have to take turns using the Internet. I picture a family with a few school kids and can see how miserable that must be.

The surveys produced a long list of other ways that poor broadband was hurting households. Number one was the inability of people to work at home. Many people said they could work at home more often if they had broadband. A few respondents want to start home businesses but are unable to because of the poor broadband. Another common complaint was the inability for kids to do schoolwork, or for adults to pursue college degrees on line.

The problems many people reported were even more fundamental than these issues. For instance, there were households saying that they could not maintain a good enough connection to bank online or pay their bills online. There were respondents who say they can’t shop online. Many households complained that they couldn’t offload cellular data at home to WiFi, driving up their cellular bills. A number of homes would like to cut the cord to save money but can’t stream Netflix as an alternative to cable.

When you look the raw data behind these kinds of surveys you quickly see the real issues with lack of broadband. In today’s society, not having home broadband literally takes a home out of the mainstream of society. It’s one thing to look at the national statistics and be told that the number of homes without broadband is shrinking. But it’s an entirely different story when you see what that means for the millions of homes that still don’t have adequate broadband. My guess is that some of the areas covered by these surveys show as underserved on the FCC maps – when in fact, their broadband is so poor that they are clearly unserved, ignored and forgotten.

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In March Congress passed a new $600 million grant/loan program to build rural broadband. The project has been labeled as the e-Connectivity Pilot and it’s expected that the specific rules for seeking the funding will be released early on 2019. The USDA sought public comments on the program in September and is now working out the details of how the awards will be made.

Anybody interested in these grants should get serious about it now, since it’s likely that the grant application window might not be any longer than 60 to 90 days. Getting ready means having a detailed and solid business plan as well as already having a source of funding for any parts of a project not covered by these grants. The grants are also likely to include provisions like getting a professional engineer to approve the network design – so designs need to be specific and not generic. It’s likely that the USDA will stick with their existing grant application process – and those forms have always been a bear to complete.

There is one huge hurdle to overcome for this program since an application can’t cover an area that has more than 10% of households with access to broadband speeds of at least 10/1 Mbps. Considering that the CAF II awards and more recent CAF II reverse auctions awards already will supposedly provide this kind of speed to huge swaths of the country, there are not a lot of areas left that will meet this requirement.

Claiming that an area meets the 90% unserved threshold will be also be difficult because grant applications can be challenged by carriers that serves the grant area today. I have to assume that CAF II reverse auction winners will also be able to challenge. The big rub is that the original CAF II award winners still have until 2020 to complete their build-out and they will certainly challenge awards for any CAF II area that has not yet been updated. The CAF II reverse auction winners have ten more years to complete their buildout. The USDA will likely be obligated to reject an application that encroaches on any of the CAF II footprint – even if those areas don’t have broadband today.

This gets even more complicated since the CAF II reverse auction awarded funding to fixed wireless and satellite providers. They were funded to serve specific little pockets of unserved homes, but it won’t be hard for them to claim that the CAF II award dollars will allow them to serve much larger areas than the tiny boundaries they bid on.

The process of proving a study area isn’t served will be further complicated by the USDA’s reliance on the FCC’s broadband maps, which we all know to be highly inaccurate in rural America. This all adds up to mean that an applicant needs to prove the area doesn’t have broadband today and will not be getting it over the next decade from one of the CAF winners. They will also need to overcome any errors in the FCC maps. This is going to be hard to prove. I expect the challenge process to be brutal.

From the instant I saw the 90% unserved test, I’ve assumed that the most likely candidates for these grants will be somebody that is already planning on building broadband across a large footprint. If such an applicant is careful to only identify the scattered homes that meet these grant rules, then this funding can help to pay for a project they were going to build anyway. The other natural set of applicants might be those companies that already took CAF II funding – they could use these grants to fill in unserved homes around those build-out areas. The industry is going to be in an uproar if a lot of this funding goes to the big incumbent telcos (who won’t challenge their own applications).

Another issue to consider is that the USDA can award funding as a combination of grants and loans. These awards will surely require matching funding from an applicant. Anybody that is already planning on funding that matching with bank or other financing might find it impossible to accept USDA loans for a portion of a project. USDA loan covenants are draconian – for example, USDA loans usually require first priority for a default, which will conflict with commercial lenders. It’s always been nearly impossible to marry USDA debt with other debt.

rant applicants should also be aware that the USDA is going to be highly leery of awarding money to start-ups or somebody that is not already an ISP. The agency got burned on such grants awarded with the stimulus grants and has indicated that they are looking for grant award winners to have a strong balance sheet and a track record of being an ISP. This will make it nearly impossible for local governments to go after the money on their own. Chances of winning will be greatly enhanced by public/private partnerships with an existing ISP.

I know my take on the grants sound highly pessimistic. Congress saddled these grants with the 90% unserved test at the coaxing of the big telcos who wanted to make sure these funds weren’t used to compete against them. Past USDA grants had the opposite requirement and could consider awards to areas that didn’t have more than 10% of houses with broadband. However, if you are able to identify a service area that can survive the challenge process, and if you have the matching funded lined up, these grants can provide some nice funding. I’m not taking any bets, though, on the USDA’s ability to award all of the money – there might not be enough grant applications that can make it through the gauntlet.

Now that most of the CAF II money and A-CAM money has been awarded, what’s next for rural broadband? If you ask the FCC that question they are likely to answer that there might yet be one more CAF II auction to fund the 261,000 homes that went unclaimed in the last auction. However, I think this is a much bigger question.

There are still tens of millions of homes that don’t have a broadband option that meets the FCC’s current definition of 25/3 Mbps. That includes all of the places that were funded by the CAF II funds provided to the big telcos and that were only required to provide broadband with speeds of 10/1 Mbps. It also includes numerous other homes that don’t have fast broadband and that are mis-categorized by the inadequate FCC broadband maps that are populated falsely by the big ISPs.

One of CCG’s products is performing surveys and related market research in rural areas. We’ve done a lot of surveys and also asked people to take speed tests in rural communities where the actual speeds at homes are significantly lower than the advertised speeds and the speeds shown on the FCC maps. I’m not just talking about rural farms, but also in sizable towns like county seats where the broadband is still pretty crappy.

It’s obvious that this FCC is working hard to be able to claim that they have taken care of the rural broadband problem. They want to say that they’ve funded broadband everywhere and that their job is done. What they are never going to admit is that the job will never be done until rural areas have the same kind of broadband infrastructure as cities.

This particular FCC is pretending that the need for broadband is sitting still, when in fact the demand for household broadband, both for speeds and for total download volumes keep doubling every three or four years. By the time the current FCC chairman has been in his seat for four years, the comparative quality of rural broadband will have halved due to this increase in demand.

Don’t interpret what I just said to mean that I have disdain for the current FCC. The last FCC under Chairman Tom Wheeler was a huge contributor to the problem when they awarded billions of dollars to the big telcos to make broadband upgrades over seven years to 10/1 Mbps – at a time when 10/1 Mbps already didn’t meet the definition of broadband. That was obviously a political decision since the original plan was to award all of the CAF II funds by reverse auction – which would have helped to fund a lot of rural fiber.

Even if the FCC was highly motivated to solve the rural broadband gap they don’t have the tools to do so. The FCC’s only tool for funding more broadband is the Universal Service. I wrote a blog last week noting how this fund is already overcommitted. Since I wrote that blog I looked at my own cellphone bills and my family alone is contributing several hundred dollars per year towards the USF fund. We are not going to get the many billions we need to expand broadband by taxing landline and cellphone users.

The fix needs to come from Congress. That doesn’t seem likely from the current Congress that already approved a $600 million fund for rural broadband grants and then added on a provision that made the grants nearly impossible to implement. Clearly influenced by lobbyists, Congress added a provision that the grants couldn’t be used in areas where more than 10% of homes already have 10/1 Mbps broadband – and there are very few such areas.

I honestly have a hard time understanding Congress’s reluctance to address rural broadband. When I go to rural counties these days I’m told that getting better broadband has become the number one local issue. I know that rural folks and rural politicians are pleading with their state and national representatives to find broadband funding.

I also know that most politicians say they are in favor of rural broadband. I’ve only seen a handful of politicians in the last decade who told their constituents that they don’t support rural broadband funding. I’ve also found that rural broadband is a nonpartisan issue and at the local level politicians of both parties understand that communities need better broadband.

I wish I could end this blog by suggesting a solution for the problem, but there isn’t any unless the states and the federal government decide at some point to help. State broadband programs providing matching grants have seen some success. I’m sure that federal matching grants would also help as long as they weren’t structured to be giveaways to the big ISPs.

Like this:

The FCC is in the process of creating its first report to Congress required by the Ray Baum Act, which is the bill that reauthorized the FCC spending for 2019 and 2020. That bill requires the FCC to create a report every two years that, among other things assesses the “state of competition in the communications marketplace, including competition to deliver voice, video, audio, and data services among providers of telecommunications, providers of commercial mobile service, multichannel video programming distributors, broadcast stations, providers of satellite communications, Internet service providers, and other providers of communications services”.

The FCC accepted comments about what should be included in its first report, and as you might imagine received a wide variety of comments from the industry and other interested parties.

In typical big carrier fashion, the NCTA – The Internet & Television Association, the lobbying group representing the largest ISPs filed with the FCC arguing that the broadband marketplace is already ‘wildly competitive’. The big ISPs have a vested interest in the FCC reaching such a conclusion, because that would mean that the FCC wouldn’t have to take actions to create more competition.

The reasoning the big carriers are using to make this claim is ironic. They argue that the FCC shouldn’t use its own 25/3 Mbps definition of broadband since the FCC is currently spending billions of dollars in the CAF II program to deploy broadband that meets a lower standard of 10/1 Mbps. They say that if US broadband is examined for the amount of competition at the lower 10/1 threshold that most markets in the US are competitive. That’s ironic because the FCC was pressured into giving all of the CAF II money to the big telcos after intense lobbying and the funds were originally intended to be awarded through a reverse auction where ISPs would have been rewarded for building broadband capable of delivering speeds up to 1 Gbps.

Further, if the FCC was to accept the idea that 10/1 Mbps is acceptable broadband then the FCC would probably be obligated to count cellular broadband as an economic substitute for landline broadband since it delivers speeds in the same range as the CAF II deployments.

However, making that same determination is impossible at faster speeds. Even the FCC’s own highly-skewed mapping data shows there are not many households in the country with two options for buying 100 Mbps service. Where households have two choices for buying 25/3 Mbps broadband the second option is almost always DSL, which the big telcos are letting die a natural technological death, and which often delivers speeds much slower than advertised. As I’ve written about in this blog, my firm has done surveys in numerous communities where the delivered speeds for both cable modems and DSL were significantly slower than the advertised speeds and certainly slower than the data in the FCC database that is collected from the big ISPs and used to create the FCC’s broadband coverage maps and other statistics.

The only way to claim that broadband is ‘wildly competitive’ is to count broadband speeds slower than the FCC’s 25/3 Mbps definition. If the FCC was to accept cellular broadband and satellite broadband as the equivalent of landline broadband, then a large majority of homes would be deemed to have access to multiple sources of broadband. I would restate the NCTA’s ‘wildly competitive’ claim to say that a majority of homes in the country today have access to multiple crappy sources of broadband.

We’ll have to see what the FCC tells Congress in their first report. I suspect their story is going to be closer to what the big ISPs are suggesting than to the reality of the broadband marketplace. This FCC already seriously considered accepting cellular and satellite broadband as an equivalent substitute for landline broadband because doing so would mean that there are not many places left where they need to ‘solve’ the lack of broadband.

The FCC finds itself in an unusual position. It gave up regulation of broadband when it killed Title II regulation. Yet the agency is still tasked with tracking broadband, and they are still required by law to make sure that everybody in the country has access to broadband. Let’s just hope that the agency doesn’t go so far as to tell Congress that their job is done since broadband is already ‘wildly competitive’.